Benchmark Regulations

• Prior to January 1, 2021, MSCI Limited was an EU regulated benchmark administrator authorized under Article 34 of the EU BMR by the UK FCA and on the ESMA register per Article 36 of the BMR.
• As of January 1, 2021, MSCI Limited is and remains authorized as a UK benchmark administrator regulated by the UK FCA (and can be found on the FCA Financial Services Register), but is considered a “third country” UK administrator vis-a-vis the EU and does not appear on the ESMA register [for these indexes] per Article 36 of the EU BMR unless and until the EU grants the UK “equivalence” or until MSCI is granted “endorsement” or “recognition”.
• On October 5, 2023, MSCI Deutschland GmbH (located and registered at Junghofstrasse 22-26, Frankfurt am Main, Germany) was granted authorization by Germany’s Federal Financial Supervisory Authority (“BaFin”) as an EU benchmark administrator for MSCI equity, blended and fixed income indexes. MSCI Deutschland GbmH is administering the MSCI Climate-Transition Benchmarks (CTB) and Paris-Aligned Benchmarks (PAB)since January 2, 2024. MSCI Deutschland GmbH may administer additional MSCI indexes in the future and additional information will be provided in advance of doing so.

As of October 5, 2023, MSCI Deutschland GmbH is authorized as an EU benchmark administrator regulated by the Germany’s Federal Financial Supervisory Authority (“BaFin”) and thereby is in the ESMA register.

Prior to the expiration of the Brexit transition period on December 31, 2020, MSCI Limited was listed on both the FCA’s register and on ESMA’s register for benchmark administrators. Pursuant to ESMA's notice on March 9, 2021, as of the date of the expiration of the Brexit transition period, UK administrators (including MSCI Limited) were removed from the ESMA register and became third country administrators in the EU. However, during the EU BMR transitional period (as described in EU BMR Article 51) EU supervised entities can use third country benchmarks even if they are not included in the ESMA register.

The EU Commission adopted a Delegated Act on 14 July 2023 to extend this transitional period by two years until 31 December 2025. This Delegated Act was published in the Official Journal of the EU on 23 October 2023 and entered into force from 26 October 2023. As a consequence, supervised entities are able to use third country benchmarks during this extended transitional period.

This does not affect MSCI’s authorization with the UK FCA as a UK administrator, and MSCI will continue to appear on the UK Financial Services Register

As per the above, all third country benchmarks are permitted to be used in the EU until the end of the EU BMR transitional period, until December 31, 2025.

During the EU BMR transitional period, MSCI will continue to develop and execute plans in consideration of regulatory requirements and in advance of any applicable deadlines.

• Prior to January 1, 2021, MSCI Limited was an EU regulated benchmark administrator authorized under Article 34 of the EU BMR by the UK FCA and on the ESMA register per Article 36 of the BMR.
• As of January 1, 2021, MSCI Limited is and remains authorized as a UK benchmark administrator regulated by the UK FCA (and can be found on the FCA Financial Services Register), but is considered a “third country” UK administrator vis-a-vis the EU and does not appear on the ESMA register per Article 36 of the EU BMR unless and until the EU grants the UK “equivalence” or until MSCI is granted “endorsement” or “recognition”.

• MSCI equity benchmark family - benchmark statement
• MSCI blended benchmark family - benchmark statement
• MSCI fixed income benchmark family - benchmark statement
• MSCI digital assets benchmark family – benchmark statement
• MSCI property benchmark family - benchmark statement
• MSCI property fund (with published NAVs) benchmark family - benchmark statement
• MSCI Real Estate - BMR Benchmarks Methodology Specifications

• The ESG disclosures for indexes are provided as per the amended EU BMR (based on the Commission Delegated Regulation (EU) 2020/1816 of July 17, 2020) and the UK BMR.
• ESG factors in the benchmark statement are available through the MSCI Index Profile Tool for all the MSCI indexes in the equity benchmark family, blended benchmark family and fixed income benchmark family.
• ESG factors in the methodology can be accessed together with the methodology documents governing a specific MSCI index for the equity benchmark family, blended benchmark family and fixed income benchmark family.

• The list of MSCI indexes in the equity benchmark family, blended benchmark family, digital asset benchmark family and fixed income benchmark family eligible for use under UK BMR and EU BMR are available to clients on MSCI’s client support site.
• The list of MSCI Private Real Estate Indexes in the MSCI property benchmark family and the MSCI Property Fund (with published NAV) benchmark family can be found in the “MSCI Real Estate – BMR Benchmarks Methodology Specifications” above.

As per the above, all third country benchmarks are permitted to be used in the EU until the end of the EU BMR transitional period, until December 31, 2025.

During this time, MSCI will continue to develop and execute plans in consideration of regulatory requirements and in advance of any applicable deadlines.